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Bundle Date Translated severed letter Summaries under Summary descriptor 2002-10-11 28 October 2002 External T.I. 2002-0134785 F- Partitioning of Shares Income Tax Act- Section 248- Subsection 248(1)- Property interest in trust is a single property even if held as units Income Tax Act- Section 248- Subsection 248(20) s. 248(20) might apply if a partition results in the issuance of whole shares Income Tax Act- Section 248- Subsection 248(21) s. 248(21) could apply to partitioning a share if the corporation could issue fractional shares on the partition satisfying the FMV test, and similarly for partitioning MFT units (viewed as a single property) Income Tax Act- Section 98- Subsection 98(3) partners not permitted to receive divided interest in shares on s. 98(3) wind-up 28 October 2002 External T.I. 2002-0117595 F- REVENU EXPERT-COMPTABLE Income Tax Act- Section 9- Nature of Income accountants required to individually recognize professional income earned by them as employees of an NPO corporation 2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103 Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) 25 October 2002 External T.I. 2002-0137705 F- Butterfly Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e) CCRA will permit UCC to be split on a pro rata basis under s. 85(1)(e)(i) where the butterfly entails s. 85(1) drop-downs to Newco subs of DC followed by their transfers to TCs 4 November 2002 Internal T.I. 2002-0160697 F- REPARTITION DU PLAFOND Income Tax Act- Section 125- Subsection 125(5)- Paragraph 125(5)(a) s. 125(5)(a) did not apply to a CCPC for its 2nd 2000 taxation year resulting from an acquisition of control causing it to be associated with a different CCPC 22 October 2002 External T.I. 2002-0162835 F- Recbles Recd. after Disp. of Farm. ...

Income Tax Act- Section 50- Subsection 50(1)- Paragraph 50(1)(b)- Subparagraph 50(1)(b)(iii)- Clause 50(1)(b)(iii)(A) “insolvent” means unable to pay one’s debts/ can’t be insolvent if nil liabilities and assets 25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance compensation under the CHRA for lost wages and expenses would be a retiring allowance – reasonable (e.g., under $5,000) compensation for pain and suffering would be non-taxable Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 ...

Regarding the requirements in s. 84.1(2.31)(g) or s. 84.1(2.32)(h) for a timely transfer of business “management” to the children (specified in s. 84.1(2.3)(i) to refer to the direction or supervision of business activities) CRA stated: [W]here the parent remains a director of Parent Inc. and steps are not taken to completely and permanently cease to hold such office, within the time periods stipulated by paragraphs 84.1(2.31)(g) and 84.1(2.32)(h), including any longer period that is reasonable in the circumstances, the requirements of subparagraphs 84.1(2.31)(g)(ii) and 84.1(2.32)(h)(ii) would not be satisfied … regardless of whether the parent is the sole director or one of the directors, and regardless of whether the direction of the day-to-day activities is in the hands of the children. ...

These are additions to our set of 3,005 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,024 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 3,139 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 3,159 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,202 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-09 26 February 2025 Internal T.I. 2023-0985151I7 F- Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense contingent dividend prospect likely did not support a deduction for an obligation to reimburse legal fees Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible Income Tax Act- Section 42- Subsection 42(1)- Paragraph 42(1)(b)- Subparagraph 42(1)(b)(ii) s. 42(1)(b)(ii) might apply to the vendor’s agreed reimbursement, post-sale, of the sold corporation’s legal costs of a failed suit 22 May 2024 External T.I. 2024-1016211E5 F- Mineral Resource Cert- XXXXXXXXXX Income Tax Act- Section 248- Subsection 248(1)- Mineral Resource- Paragraph (d)- Subparagraph (d)(i) NRC certification received 2000-06-09 11 May 2000 External T.I. 2000-0009605 F- Démolition d'un immeuble Income Tax Regulations- Regulation 1100- Subsection 1100(11) Reg.1100(11) does not limit a terminal loss Income Tax Act- Section 20- Subsection 20(16) rental property restriction rule does not apply to a terminal loss Income Tax Act- Section 13- Subsection 13(21.2) s. 13(21.2) does not apply to an individual nor to a corporation demolishing a building while retaining the land for more than 30 days Income Tax Act- Section 54- Superficial Loss no superficial loss where demolition of building Income Tax Act- Section 40- Subsection 40(3.3) no suspended loss where demolition of building 15 May 2000 External T.I. 2000-0001995 F- CONGE SANS SOLDE-REGIME DISTINCT Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) payment of premiums by employee during unpaid leave did not create a separate plan, so that any benefits received would still be taxable 11 May 2000 Internal T.I. 2000-0008270 F- Perte finale disposition bâtiment Income Tax Act- Section 13- Subsection 13(21.1)- Paragraph 13(21.1)(b) s. 13(21.1)(b) would apply to reduce terminal loss even if the land was disposed of at a loss in a previous year 24 May 2000 Internal T.I. 2000-0017677 F- PENSION ALIMENTAIRE Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount payments made pursuant to a separation agreement in order to maintain a financial balance between them rather than for maintenance, were not support amounts 17 May 2000 External T.I. 1999-0011695 F- Revenu protégé- options et dividendes follow-up in 2000-0040405 F Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income of Pubco allocated to option granted to a minority shareholder to acquire its shares, but reduced by Pubco dividends 17 March 2000 APFF Roundtable Q. 11, 2000-0008260 F- DEDUCTION POUR PLACEMENTS Income Tax Act- Section 181.2- Subsection 181.2(4)- Paragraph 181.2(4)(b) balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances” ...

These are additions to our set of 3,324 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...